Smith Regulatory Strategies
1. The Dodd-Frank Act amended the Fair Debt Collection Practices Act (FDCPA) to give the Consumer Financial Protection Bureau rulemaking authority. The CFPB announced its goal of modernizing rules under the FDCPA by issuing an advance notice of proposed rulemaking in November 2013 seeking information on debt collection. The notice included 162 questions that cover.
By Brian W. Smith, Managing Director, Smith Regulatory Strategies, and Chad Burhance, Partner, NewOak In comparison to Basel I and II rules, the recently implemented Basel III regulations (the Regulations) will alter the treatment of bank-owned life insurance (BOLI) separate accounts dramatically. In short, the Regulations require bank management to examine the portfolios of bank-owned.
1. Wells Fargo announced that it would continue dealer-reserve pricing in its indirect automobile lending operation. Such an approach is a ready-made fair lending red flag that has been in regulator’s cross hairs for some time. Our staff has reviewed indirect lending programs at a variety of institutions and analyzed interest rate overages to ensure.